Whether bank robbery (18 U.S.C. § 2113) qualifies as a 'crime of violence' under 18 U.S.C. § 924(c)(3)(A)

QUESTIONS PRESENTED I Whether bank robbery (18 U.S.C. § 2113) which may be committed by unintentionally intimidating a victim or by presenting a teller with a demand note, has as an element “the use of physical force against the person or property of another.” under 18 U.S.C. § 924( c)(3)(A). I. While the Eleventh Circuit (and many other circuits) has held fast to the notion that bank robbery by intimidation qualifies as a “crime of violence” under § 924 (c)’s elements clause, some other circuits have recently determined similar state statutes to not qualify as “violent felonies” under the elements clause of the Armed Career Criminal Act, creating a conflict amongst the Circuit courts. i